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The Double Irish and Single Malt BEPS tools enable Ireland to act as a confidential "Conduit OFC" rerouting untaxed profits to places like Bermuda (e.g. it must be confidential as higher-tax locations would not sign full tax treaties with locations like Bermuda), the Capital Allowances for Intangible Assets (CAIA) BEPS tool (also called the ...
EU Commission's outline of Apple's hybrid–double Irish BEPS tax structure in Ireland, that used two branches inside a single company based on private rulings from the Irish Revenue Commissioners in 1991 and 2007. [214] Margrethe Vestager European Commissioner for Competition who led case SA:38373 on illegal State aid to Apple in Ireland (2004 ...
Single Malt – takes the Double Irish tax-residence concept around "management and control", and worded directly into specific bilateral tax treaties (Malta, UAE). [156] Capital Allowances for Intangible Assets – introduced in the 1997 TCA but expanded in the 2009 Finance Act, [11] and made tax-free in the 2015 Finance Act for Apple. [u] [178]
The issue was Apple's variation of the Double Irish tax system, which, from 2004 to 2014, Apple used to shield €110.8 billion [10] [11] of non–US profits from tax. [12] On 9 January 2015, Apple informed the Commission [a] that it closed its hybrid–Double Irish, base erosion and profit shifting (BEPS) tool. [13]
Irish employee tax rate (single and married) versus the OECD in 2017. [11] The OECD's 2018 Taxing Wages shows Ireland's employee tax on wages, which is the total tax (PAYE and EE–PRSI less SS Benefits) paid by Irish employees, as a % of their gross wages, is also one of the lowest in the OECD. Of the 35 OECD members in 2017, the average Irish ...
Civil fraud: If the IRS believes you have committed tax evasion, but the offense is not considered criminal, you could face a penalty of 75% of the tax underpayment attributable to fraud.
Single malt is another BEPS tax scheme designed to replicate the double Irish, which is impossible after 2020. [36] [37] It relies on specific wording in bi-lateral Irish tax treaties (particularly with Malta and the United Arab Emirates) to re-create the double Irish system and its effective tax rate of <1%.
An American woman who previously posed as heiress to a fortune faces extradition to Northern Ireland to face charges in connection with alleged schemes in which she is accused of duping investors ...